The assignees of an unregistered 1995 assignment of a decree for specific performance sought execution. The judgment-debtors’ legal heirs objected on the ground that the assignment was unregistered and therefore unenforceable. The Executing Court accepted this objection relying on K. Bhaskaram  v. Mohammad Moulana (died) and others  AIR 2005 AP 524 holding that the assignment of a decree involving immovable property requires compulsory registration under Section 17(1)(e). On revision, the High Court reversed the Executing Court’s order. On appeal, the Supreme Court held that a decree for specific performance does not create or transfer any right, title or interest in immovable property; rights arise only when a registered sale deed is executed pursuant to the decree. The contract of sale subsists even after a decree, and a decree for specific performance is in the nature of a “preliminary decree” which merely enables the decree-holder to obtain a sale deed through the court. Since the decree itself does not purport to create, declare, assign, limit, or extinguish any right or interest in immovable property, Section 17(1)(e) is not attracted. Consequently, an instrument assigning such a decree does not require registration. The Court approved the Bombay High Court view in Amol v. Deorao  2011 SCC OnLine Bom 11  and overruled the contrary view in K. Bhaskaram, and further held that Order 21 Rule 16 CPC permits execution by an assignee of a decree. Upholding the High Court, the Supreme Court held that the assignment deed  was valid even without registration and execution could not be denied on that ground.(CA No. 13835 of 2025 (SLP (C ) No. 3532 of 2028 ,  Dt.  19.11.2025.